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attributable to negligence or disregard of rules or regulations.
Negligence is a "lack of due care or a failure to do what a
reasonable person would do under the circumstances." Leuhsler v.
Commissioner, 963 F.2d 907, 910 (6th Cir. 1992), affg. T.C. Memo.
1991-179. Negligence also includes any failure to make a
reasonable attempt to comply with the provisions of the Code,
exercise reasonable care in return preparation, keep proper books
and records to properly substantiate items, or have a reasonable
basis for a position taken. See sec. 6662(c); sec. 1.6662-
3(b)(1), Income Tax Regs.
In determining whether petitioners were negligent in the
preparation of their returns, we take into account their business
experience. See Glenn v. Commissioner, T.C. Memo. 1995-399,
affd. 103 F.3d 129 (6th Cir. 1996).
An exception to imposition of the negligence penalty is
provided if it is shown that there was a reasonable cause for the
understatement and the taxpayer acted in good faith. Petitioners
bear the burden of proving that they are not liable for the
penalty under section 6662(a). See Bixby v. Commissioner, 58
T.C. 757, 791 (1972).
Petitioners' primarily argue that, because Raymond "never
believed he was involved in a trade or business", they are not
liable for the accuracy-related penalty. To the contrary,
Raymond did know that he bought, sold, and traded sports
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